Compliance Policy

Document Number000838
Date Approved30 November 2007
Date Last Amended19 August 2010


1.      Introduction

 The University of Newcastle is committed to delivering its strategic and operational objectives in accordance  with the law and principles of good governance, and with honesty, fairness, trust, accountability and respect.(1)  To do this, the University must comply with a diverse range of State and Commonwealth legislation; regulatory requirements, and internal policies and frameworks.  The manner in which the University discharges its compliance obligations demonstrates our core values; This policy aims to assist the University  in its efforts to appropriately manage its compliance obligations and is an important element in the University’s approach to effective business management with appropriate examination of risk.

This Compliance Policy conforms to the Australian Standard AS 3806 – 2006 Compliance Programs. It is supported by the University’s Compliance Framework and the Register of Compliance Obligations which lists the University of Newcastle’s primary compliance obligations. The Compliance Policy should be read in conjunction with those documents.

2.      Policy Intent

To enable the University to meet its compliance responsibilities; to manage its compliance risks; and to conduct its activities and business, lawfully and responsibly.

3.      Scope

This policy applies to all faculties, divisions, and business units of the University of Newcastle, and to all persons employed by or representing the University.

4.      Definitions

In the context of this policy:

compliance means adhering to the law, industry codes and organisational standards;

compliance culture means  the sum of values, ethics and beliefs that exist throughout an organisation and which interact with the organisation’s structures and control systems to produce behavioural norms that are conducive to compliance outcomes;

compliance failure means an act or a failure to act that results in not meeting  the organisation’s compliance obligations, processes or behavioural norms;

compliance program means the series of activities designed  to monitor, manage and inform the University Council, its committees and senior managers of compliance risk across the University; and ultimately  to achieve compliance; 

Council means the University of Newcastle Council - the governing body that has overall responsibility for the direction and control of the University;

Register of Compliance Obligations is the list of compliance requirements that have been identified by the University;

5.      Policy Provisions

5.1.     Commitment

  1. The University is committed to the maintenance and continuous improvement of a compliance framework and processes, and to the development of a compliance culture throughout the University. The University will allocate appropriate resources to the development, implementation and continuous improvement of its compliance program.
  2. Council, through the Audit and Risk Management Committee, is responsible for overseeing the University’s compliance with legislation,  regulatory requirements, reporting obligations, and University policies.
  3. Compliance is a shared responsibility between the University, all managers, Risk and Assurance Services staff, and University representatives.
  4. Risk and Assurance Services  will have overarching responsibility for:
    1. the design and implementation of the Compliance Framework;
    2. coordinating the maintenance of, and promulgating the Register of Compliance Obligations ;
    3. providing support and training to staff where appropriate; and
    4. monitoring and reporting on compliance.
  5. All managers will be accountable for the recognition and management of compliance risks in their area and for reporting on compliance.
  6. All staff and University representatives must be aware of compliance responsibilities that apply to their area of work or activities, and ensure that their actions on behalf of the University comply with relevant laws, industry codes and organisational standards.

5.2.     Implementation

  1. The University will adopt a risk-based approach to the implementation of its compliance program.  Statutory obligations representing the greatest degree of risk to the University will be given priority in the implementation schedule.
  2. Compliance responsibilities will be identified and promulgated through the Register of Compliance Obligations.  
  3. Managers and staff will receive appropriate training in behaviours that create and support compliance.
  4. Behaviours that create and support compliance will be encouraged. Behaviours that compromise compliance will be investigated.

5.3.     Monitoring and Measurement

  1. Systems, procedures and controls will be implemented to support the monitoring of compliance obligations against the requirements of the Compliance Framework.
  2. Risk and Assurance Services will be responsible for reviewing and maintaining the Register of Compliance Obligations, the Compliance Framework,  the Compliance Policy and the information system which support the compliance program within the University.
  3. Compliance obligations and the assurance processes associated with these obligations will be assigned to University officers to ensure that obligations are actively monitored and that appropriate, ongoing assurance activities are undertaken.
  4. Risk and Assurance Services will report at least annually to Council on the University’s compliance program, via the Audit and Risk Management Committee.

5.4.     Continuous Improvement

The Compliance Policy, Framework and Register of Compliance Obligations will be reviewed on an ongoing basis by Risk and Assurance Services to identify deficiencies and ensure continuous improvement.

6.      Essential Supporting Documents 

Compliance Framework 

Register of Compliance Obligations

7.      Related Documents

Code of Conduct 000059

Australian Standard Compliance Programs (AS 3806-2006)

 

(1)  University of Newcastle Code of Conduct 000059.

Approval AuthorityVice-Chancellor
Date Approved30 November 2007
Date Last Amended19 August 2010
Date for Review19 August 2013
Policy SponsorVice-Chancellor
Policy OwnerUniversity Secretary
Policy ContactManager, Risk Services
Amendment History

Amended for considtency with Australian Standard for Compliance Programs (AS3806-2006), Approved Vice-Chancellor 19 August 2010

Amended Policy Contact 24 March 2010

Minor amendment approved by Vice-Chancellor 27 April 2009

Revision Approved Council 30 November 2007